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Home My WebLink About00-03194 " , ~ - -~ ,~'. I'~, .-0,_''-"__. ,"c . . . . . . . . "'''' '" '" "'''''''''' . . '" "'''' '" . . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY . . PENNA. STATE OF . . . . RONALD P. FRANK, . No. CIVIL TERM 00-3194 PLAINTIFF . . VERSUS . CAROL D. FRANK, . . . DEFENDANT . . DECREE IN DIVORCE . . . . . &t /j..: 0'" ,JdtD , IT IS ORDERED AND . . . ~~ AND NOW, DECREED THAT RONALD P. FRANK , PLAINTIFF, . . . CAROL D. FRANK , DEFENDANT, AND . ARE DIVORCED FROM THE BONDS OF MATRIMONY. . . THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; . . . NONE . . . . ATTEST: J. ~~~OTHONOTAR' . . . . . . . . . . '" "'''' '" '" "'''' '" '" '" '" '" '" '" "'''' . . . ,-. -- ~. ". '0;. "''''''' '" . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . RONALD P. FRANK, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW NO. 00-3194 CIVIL TERM CAROL D. FRANK, Defendant IN DIVORCE PRAECIPE TO TRANSMIT RECORD o THE PROTHONOTARY: Transmit the record, together with the following information, to the Court for entry of a ivorce decree: 1. Grounds for Divorce: Irretrievable breakdown under Section 3301 (c).. 2. Date and manner of service of the Complaint: Acceptance of Service filed by Defendant's counsel indicating service on or about 15 June 2000. 3. Complete either Paragraph (a) or (b): (a) Date of execution of the Affidavit of Consent required by Section 3301 (c) of the Divorce Code: By Plaintiff: 10 November 1999 By Defendant: 18 November 1999 (b) (1) Date of execution of the Affidavit required by Section 3301 (d) of the Divorce Code: (2) Date of filing and service of the Plaintiff's Affidavit upon the Respondent: 4. Related claims pending: None. 5. Complete either (a) or (b): (a) Date and manner of service of the Notice of Intention to File Praecipe to Transmit Record, a copy of which is attached: (b) Date Plaintiff's Waiver of Notice in Section 3301 (c) Divorce was filed with the Prothonotary: dated 18 August 2000 and filed contemporaneously herewith. Defendant's Waiver of Notice in Section 3301 (c) Divorce was filed with the Prothonotary: dated 18 August 2000 and filed contemporaneously herewith. Date: I de? 'DO BY~_ (hf\ Q~ uel L. ~ Attorney for Plaintiff u 'Cc .-" ~",""-,.,,.~I. ~.~''''"~C . ~I~' o 5;: LJ ~::": rnCr. -::":[1,' :S- f'" (jjt' ~:e~:~ -"" 2:("" 3>.r;;;. '- ;? ~~ :n C'() t-., C:2 c..") rn '-i I \~ ;r ~~~ ~ ~ I~ ... r ... RONALD P. FRANK, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW NO. 00- .$/q'{ CIVIL TERM CAROL D. FRANK, Defendant IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in court. If you wish to defend against the claims set forth in the foregoing pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree in divorce or annulment may be entered against you by the court. A judgment may also be entered against you for any other claim or relief requested in these papers by the plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at: Office of the Prothonotary Cumberland County Court House 1 Courthouse Square Carlisle, Pennsylvania 17013 IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone: (717) 249-3166 1 , . RONALD P. FRANK, ) IN THE COURT OF COMMON Plaintiff ) PLEAS OF CUMBERLAND COUNTY, ) PENNSYLVANIA ) vs. ) CIVIL ACTION - LAW } ) NO. 00- .WI'! CIVIL TERM CAROL D. FRANK, ) Defendant ) IN DIVORCE NOTICE OF AVAILABILITY OF COUNSELING TO THE WITHIN-NAMED DEFENDANT: You have been named as the Defendant in a Complaint in a divorce proceeding filed in the Court of Common Pleas of Cumberland County. This notice is to advise you that in accordance with Section 3302(d) of the Divorce Code, you may request that the court require you and your spouse to attend marriage counseling prior to a divorce being handed down by the court. A list of professional marriage counselors is available at the Domestic Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from this list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. If you desire to pursue counseling, you must make your request for counseling within twenty days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. 2 - " ... RONALD P. FRANK, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW NO. 00- .319'f CIVIL TERM CAROL D. FRANK, Defendant IN DIVORCE COMPLAINT IN DIVORCE AND NOW comes the above-named Plaintiff, RONALD P. FRANK, by his attorney, Samuel L. Andes, and makes the following Complaint in Divorce: 1. The Plaintiff is RONALD P. FRANK, an adult individual who currently resides at C A", t> )),11, ~. 510 Porsha Terrace, Cumberland County, Pennsylvania. 2. The Defendant is CAROL D. FRANK, an adult individual who currently resides at 560 Old Orchard Lane, Camp Hill, Cumberland County, Pennsylvania. 3. Both the Plaintiff and Defendant have been bona fide residents of the Common- wealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on 5 April 1986 in Wormleysburg, Pennsylvaniil. 5. There have been no prior actions of divorce or annulment between the parties. 6. This marriage is irretrievably broken. 3 - \-...d . 7. Plaintiff has been advised of the availability of marriage counseling and the Plaintiff may have the right to request that the Court require the parties to participate in counseling. 8. The Plaintiff requests this Court to enter a Decree of Divorce. WHEREFORE, Plaintiff requests this Court to enter a decree in divorce pursuant to the Divorce Code of Pennsylvania. I verify that the statements made in this Complaint are true and correct. I understand that any false statements in this Complaint are subject to the penalties of 18 Pa. C.S. 4904 (unsworn falsification to authorities). DATE: 6 f{~ z:ouu ~ ;;~/ RONALD P. FRANK ~ Samuel L. Andes Attorney for Plaintiff Supreme Court ID 17225 525 North 12th Street Lemoyne, PA 17043 4 RONALD P. FRANK, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW NO. 00-3194 CIVIL TERM CAROL D. FRANK, Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on 24 May 2000 and served upon the Defendant on or about 30 May 2000. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing of the complaint and the date of service of the complaint on the Defendant. 3. \ consent to the entry of a final decree in divorce either after service of a Notice of Intention to Request Entry of the Decree or upon filing of my Waiver of the Notice of Intention to Request Entry of the Decree. 4. I have been advised of the availability of marriage counseling and understand that the Court maintains a list of marriage counselors and that I may request the Court to require my spouse and I to participate in counseling and, being so advised, do not request that the Court require that my spouse and I participate in counseling prior to the divorce becoming final. I verify that the statements made in this Affidavit are true and correct and I understand that false statements herein are made subject to the penalties of18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. I 8'/1 S/OO Date . ~fJvrCvJP~ CAROL D. FRANK II ..,;. """~JI" M" ~- -iR1 'I -......,~~-m~;f",,'~_>'iOlffiili~~~;ie;jj.:.i..iil. "-''\lIlIllliIIiIIiUlIltiliIlit~ ,L "'~.,. o c ~- ;gc.., Z~~r~ {6i~: r",-, <'-- ~' ,.t..'o ,~_ ~l .c:..../_; >C' "/ ~ ,~~ J :..., '-J ..&;; o o V) n, -0 I C'J --q ---. ::Q ~-~ -,,(.j ~-;:(~ -;, q iD ~~ II " --,,--' ~-', --, 1 RONALD P. FRANK, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW NO. 00-3194 CIVIL TERM CAROL D. FRANK, Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on 24 May 2000 and served upon the Defendant on or about 30 May 2000. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing of the complaint and the date of service of the complaint on the Defendant. 3. I consent to the entry of a final decree in divorce either after service of a Notice of Intention to Request Entry of the Decree or upon filing of my Waiver of the Notice of Intention to Request Entry of the Decree. 4. I have been advised of the availability of marriage counseling and understand that the Court maintains a list of marriage counselors and that I may request the Court to require my spouse and I to participate in counseling and, being so advised, do not request that the Court require that my spouse and I participate in counseling prior to the divorce becoming final. I verify that the statements made in this Affidavit are true and correct and I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. " , .I'tlbqlIrl- dlJlJlJ Date ~a//~q/-> RONALD P. FRANK II ;~~~'~;, ~- . .~\illo~"'_Jii"i!i~I1oIliJlf~~~iWlii"" . .. ~.~ ~, ._0'." _,,-,., >,~ . ~ ~ _ ~_ ,c"'~" _~.~ ~.-~ - ~-.-['~' ,c...lIIilllllti ". ,,' ~~lliiIiIlIlli ~ (") ,~ C) ~~ C C.) -r~ s: U) -0 G' CT1 rn r--; --(1 , -7 ::Cr <- Z-C" (.I)d-~' -<..~::- ~::C:j 3-"';::' ~}~ )> c..: () ~7 , --j ':J''j :;0 -<. ..... -< _.- , ,Il RONALD P. FRANK, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW NO. 00-3194 CIVIL TERM CAROL D. FRANK, Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301 ICI OF THE DIVORCE CODE 1. I consent to the entry of a final decree in divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees, or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this Waiver are true and correct. I understand that false statements herein are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. 'i5 J 1<6 )OtJ I ~ ~ f1.1~~ CAROL D. FRANK Date II --~~~ ~ "fl~ ~""'OO~;a,'l.IM"'~M"f~~~bJ1:i1 ."- .-", o:..;...ililIi: ""'.~ o s:: .-' ""Orr, m,--:, Z " g~~ ):';: ;:o-C ~c.' C Z =< -'-> :.11 .-../ '.- ." o c, "', ,""1 ~";; C) -n -"1 I'~ ,::-; ,-,,' :.:?". " ( ~, ~~:i-"I 55~ -< 'I RONALD P. FRANK, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW 'I I Ii: I 1:1 CAROL D. FRANK, NO. 00-3194 CIVIL TERM Defendant IN DIVORCE :1 "I Iii II " Ii WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301 ICI OF THE DIVORCE CODE 1. I consent to the entry of a final decree in divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees, or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this Waiver are true and correct. I understand that false statements herein are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Irf/J//?// r;L .:1 tJl'1# Date ~/ /~~ RONALD P. FRANK II "'.0' "~lil ~ -~ _~ ->0 '''' " ,",',,- - ~. "...._.:Itiil~,f,pjlt,~IiJi'~.-~ ,"... ~ ,,+ .. .' ~ " -~~ , -" ~,-,,~~,~, -~-, ~ '"tJf!.~ nlr';..: :?':' ;~Jt lt~; c ::c ::< ~~ - - c..."'J ..., C;J C;;, ::...., ~ ~ '...,j :..... .::;:;,: J;) -:.: ""It''''>>'1 I I , ,,~ ::.;-' II - v. ,,~ RONALD P. FRANK, Plaintiff Defendant ) ) ) ) ) ) ) ) ) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW V5. NO. 00-3194 CIVIL TERM CAROL D. FRANK, IN DIVORCE ACCEPTANCE OF SERVICE I hereby acknowledge receipt of a true and correct copy of the Complaint in divorce filed in the above action on meA. y 30 2000. f1LVl.af [) ~ 0/''''6. u~ Carol D. Frank II ~,,~;.... ,,>" -.<'^. .. , ..,. ,._ "_._'I_~."'.-w-'. ",,",~ '~*dh..WII;;'j,'~ . --~. < ~ ..,,"~. IIliJiH ~"' -,;, "-~ . ,,, r. " -'-0 C> C:) r~ ~, ~ C.J' " , "'" ""'00:; ,- rD.,I1", ::::::: .,-"'-: '2.> -;2;'" , ~ -,'C) ~r:~: ~..' ' ._),<~.") ~C) "f' ;;>" ':::,!. %,e, r_j:'" ......~. ,_J - _J-::")n"\ ~__C~ ~- 'PC ~, ~ ~. w i?: .L. {? i